PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES PROPOUNDED TO PATRICIA B. WINDLE

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES PROPOUNDED TO PATRICIA B. WINDLE

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION

MEREDITH T. RANEY, JR.,
Plaintiff,
v.
AWARE WOMAN CENTER
FOR CHOICE, INC., a Florida corporation,
EDWARD W. WINDLE, JR., and
PATRICIA B. WINDLE
Defendants.

CASE NO.: 97-1197-CV-ORL-19B

PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES PROPOUNDED TO PATRICIA B. WINDLE

Meredith T. Raney, Jr., Plaintiff, hereby requests that this Court enter an order compelling Patricia B. Windle, a Defendant, to answer certain interrogatories previously propounded to her, in support thereof saying:
FIRST ITEM
Interrogatory 2. Please list the names, business address, dates of employment, including self-employment, where you have worked in the past five years.
Answer to # 2. See objections served simultaneously herewith. I have worked for Aware Woman Center for Choice, Inc. for the last five years.
Objection. Defendants object to the information requested in paragraph 2 inasmuch as this information is irrelevant and not calculated to lead to the discovery of relevant evidence. Without waiving the above objection, Defendants will respond to the question as it relates to being employed by AWARE WOMAN CENTER FOR CHOICE, INC.
Reason to compel. Not only is this answer necessary to discover information about the issues themselves but also may lead to impeachment testimony and to information upon which punitive damages may be computed. And such infon-nation is necessary in defining the knowledge and experience of a witness, which is necessary in such cases as this one, where the health and safety of customers is of such importance.
SECOND ITEM
Interrogatory 3. Please list all occupational licenses held by yourself during the last five years, the agency issuing such licenses and the original date of issuance, when they expire and the qualifications needed to obtain such licenses.
Answer to # 3. See objections served simultaneously herewith.
Objection. Defendants object to answering interrogatory no. 3 inasmuch as the information requested is irrelevant and not calculated to lead to the discovery of admissible evidence. Additionally, the interrogatory is vague and overbroad.
Reason to compel. The answer will show that Defendant is not qualified to properly and safely operate a reproductive health service facility, necessitating the counseling and refeffal services provided by the Plaintiff. The information will also be used for impeachment purposes and discovery needed for computation of punitive damages.
THIRD ITEM
Interrogatory 4. What business related organizations have you been a member of in the past five years, stating the mailing address thereof, and any qualifications for membership?
Answer to # 4. See objections served simultaneously herewith.
Objection. Defendants object to answering interrogatory no. 4 inasmuch as the information requested is irrelevant and not calculated to lead to discovery of admissible evidence.
Reason to compel. The reason is much like the previous item. It is important to show that Patricia B. Windle is unqualified and unsafe as a 'facility' operator; it is important to show the dimensions of the facilities operated by others in a similar business. Impeachment and punitive damage information will be obtained.
FOURTH ITEM
Interrogatory 6. Please describe your part in the operation of Aware Woman
Center for Choice, Inc. during the past five years.
Answer to # 6. See objections served simultaneously herewith.
Objection. Defendants object to answering interrogatory no. 6 inasmuch as the information requested is irrelevant and not calculated to lead to the discovery of admissible evidence. Additionally, interrogatory no. 6 is vague, unclear and overbroad and Plaintiff is unable to determine specifically the information requested by Plaintiff
Reason to compel. The answer will show a number of relevant things such as this party's relationship with the police, her reasons for harassing Plaintiff, the danger she posed to customers and opportunity to witness events.
FIFTH ITEM
Interrogatory 7. At what physical locations has Aware Woman Center for Choice, Inc. conducted business during the past five years?
Answer to # 7. Aware Woman Center for Choice, Inc. has conducted business during the past five years at 1564-76 Dixie Way, Melbourne, Fl.
Objection. Defendants object to answering interrogatory no. 7 inasmuch as the information requested is irrelevant and not calculated to lead to the discovery of admissible evidence. Without waiving this objection, Defendants will respond to the interrogatory as it relates to the office of AWARE WOMAN CENTER FOR CHOICE, INC., located at 1564-76 Dixie Way, Melbourne, Florida.
Reason to compel. To discover other witnesses who can define the size of such facilities; who can disclose the danger of Aware Woman operations; provide impeachment testimony and evidence for punitive damages.
SIXTH ITEM
Interrogatory 8. Please list all business or occupational schools, courses or classes that you have attended, including the result, date, location and sponsor and the purpose for which they were taken during the past five years.
Answer to # 8. See objections served simultaneously herewith.
Objection. Defendants object to answering interrogatory no. 8 inasmuch as the information requested is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence.
Reason to compel. The answers will show that Patricia B. Windle is not a
competent, qualified, or safe manager of a reproductive health services facility and that her lack of education and training poses a severe threat to the life and health of customers.
SEVENTH ITEM
Interrogatory 9. Please state if you have been a party, either plaintiff or defendant in a lawsuit or administrative action. Other than the present matter during the past five years, and, if so, state whether you were the plaintiff or defendant, the nature of the action and the date and place in which such action was filed.
Answer to # 9. See objections served simultaneously herewith.
Objection. Defendants object to answering interrogatory no. 9 inasmuch as the information requested is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to discovery of admissible evidence.
Reason to compel. This information will help prove that Patricia B. Windle and this facility poses serious threats to the lives and health of their customers and will disclose witnesses who can testify to the desperate need for counselors such as Meredith T. Raney, Jr.
EIGHTH ITEM
Interrogatory 12. With whom have you discussed the facts and allegations of this lawsuit, other than with your attorneys and persons associated with them? Please include residence and mailing addresses and telephone numbers where they are known to you.
Answer to # 12. See objections served simultaneously herewith. Susan Hill of Raleigh, North Carolina, Mike Doughney and Lauren Nizely of Maryland, Alan Pollack, Edward W. "Ted" Windle, Roni L. Windle, Edward W. "Tod" Windle, Reid Windle, Eleanor Smeal, Catherine Spillar, Alice Cohan, Nancy Kolsin- Kintigh, Frank Oliveri, Lynn Bumpus-Hooper, Andrew Douglass, Phil Long, Nicole Youngman, and others whom I do not recall. After the news was posted on the Internet, I had many casual conversations consisting of two to five casual sentences of general conversation with a number of people as were most of the conversations listed above.
Objection. With regard to interrogatory no. 12, Defendants object to revealing the residential address and phone number of the individuals inasmuch as this information is confidential and in the event that the residential address and phone number of these individuals were divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individual's personal safety would be compromised. Without waiving this objection, Defendants will, however, respond to the other inquiries contained within interrogatory no. 12.
Reason to compel. There is no confidentiality in these conversations which may contain major admissions against interest useful in proving up the issues of this case.
NINTH ITEM
Interrogatory 13. Whom do you know that witnessed in any way the events described in or alleged by the pleadings in this case, including yourself if you are such a witness? Please include residence and mailing addresses and telephone numbers where they are known to you, together with a synopsis of what each person witnessed.
Answer to # 13. See objections served simultaneously herewith. Other than the arresting officers listed in interrogatory no. 11 above, I do not know who may have witnessed the "events."
Objection. With regard to interrogatory no. 13, Defendants object to revealing the residential address and phone number of the individuals inasmuch as this information is confidential and in the event that the residential address and phone number of these individuals were divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and. There is the possibility that the individual's personal safety would be compromised. Without waiving this objection, Defendants will, however, respond to the other inquiries contained within interrogatory no. 13.
Reason to compel. This item initially does not seem to be a "big deal" but the objection is part of an obvious scheme to slow or derail discovery. This information is not privileged and should be disclosed.
TENTH ITEM
Interrogatory 15. Who besides yourself has information concerning your income, financial net worth, and other similar accounting or economic information for the past five years? Please include residence and mailing addresses and telephone numbers where they are known to you.
Answer to # 15. See objections served simultaneously herewith.
Objection. Defendants object to answering interrogatory no. 15 inasmuch as the information requested is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. Additionally, Defendants object to revealing the residential address and phone number of the individuals inasmuch as this information is confidential and in the event that the residential address and phone number of these individuals were divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individual's personal safety would be compromised.
Reason to compel. The plaintiff is entitled to such evidence in proving punitive damages. Had the Defendants any honest fears of Plaintiff they would have named him in the original inj unction. This concern for the "personal safety" of their accountant or bookkeeper is a sham. The only dead and injured persons at Aware Woman Center for Choice, Inc. have been the customers.
WHEREFORE, Meredith T. Raney, the Plaintiff requests that the Defendant, Patricia B. Windle, be compelled to fully answer these questions.

Respectfully submitted,
Christopher F. Sapp <signed>
Post Office Box 1012
Lehigh Acres, Florida 33970
(941) 368-3922
Florida Bar Number 0097823
Attorney for Meredith T. Raney, Jr.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to Vincent G. Torpy, 930 S. Harbor City Blvd., Suite 505, Melbourne, Florida 32901 this 9th day of April, 1998.
Christopher F. Sapp <signed>
Attorney